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The applicants are Namibian individuals some of whom are employed by various institutions. They were issued with refunds by the tax authorities which are now suspected to have been fraudulent. The Namibia Revenue Authority (Namra), in pursuance of the provisions of the Act, called upon the applicants to provide documents in support of the refund, which it is claimed the applicants failed to provide. This culminated in Namra assessing the applicants’ liability and issuing instructions to the employers of the applicants to effect deductions from the applicants’ salaries and emoluments.

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